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Per CDBG program regulations on Urban Counties at 24 CFR 570.307(a): <br />"The Secretary will determine the qualifications of counties to receive entitlements <br />as urban counties upon receipt of qualification documentation from counties at such <br />time, and in such manner and form as prescribed by HUD. The Secretary shall <br />determine eligibility and applicable portions of each eligible county for purposes <br />of fund allocation under section 106 of the [HCDA] on the basis of information <br />available from the U.S. Bureau of the Census with respect to population and other <br />pertinent demographic characteristics, and based on information provided by the <br />county and its included units o f general local government." <br />1.3.2 Urban Counties are required to requalify every three federal fiscal years (FYs) <br />The three -fiscal -year Urban County qualification period is a statutory requirement,2 <br />which is also codified in CDBG program regulations at 24 CFR 570.307(d)(1): <br />"The qualification by HUD of an urban county shall remain effective for three <br />successive Federal fiscal years regardless of changes in its population..." <br />1.3.3 Purposes of Urban County qualification <br />The four main purposes are officially verifying and ensuring: <br />1. Counties meet the population threshold to be an Urban County. In general, this <br />is based on the combined population in: a) the county's unincorporated areas <br />and b) "participating" units of general local government (Participating UGLGs).3 <br />2. HUD can accurately allocate formula grant funding for the CDBG program <br />(and HOME Investment Partnerships (HOME) and Emergency Solutions Grant <br />(ESG) programs, if applicable).4 Urban County "configurations" affect formula <br />funding amounts across the entire CDBG Entitlement grantee portfolio.5 <br />3. Intergovernmental agreements or IGAs (agreements between local govemments)6 <br />for Urban Counties are legally sufficient for HUD. These legal agreements are <br />between Urban Counties and Participating UGLGs (or Metropolitan Cities). <br />4. Participating UGLGs (in Cooperation Agreements) and Metropolitan Cities <br />(in Joint Agreements) have an opportunity every three years to choose <br />whether to continue, or opt out of, participating in their Urban County. <br />2 Section 102(d) of the HCDA (42 U.S.C. 5302(d)) states: "The population of any UGLG which is included in that <br />of an urban county [...] shall be included in the population of such urban county for three program years beginning <br />with the program year that its population was first so included." <br />s The population of Metropolitan Cities is never counted towards Urban Counties, including under Joint Agreements. <br />4 The HOME and ESG programs are marked "if applicable" because not all Urban Counties receive HOME or <br />ESG funding. Some Urban Counties are not eligible and some choose not to participate in those programs. <br />s There are approximately 1,300 CDBG Entitlement Communities (cities and counties), which directly receive <br />CDBG grants annually. There are approximately 1,100 Metropolitan Cities and approximately 200 Urban Counties. <br />6 There are two types of agreements: 1) Cooperation Agreements (between Urban Counties and Participating <br />UGLGs); and 2) Joint Agreements (between Urban Counties and Metropolitan Cities [CDBG Entitlements]). <br />0 <br />560 <br />